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Ottawa, 16 February 2012

O/Ref.: 8740-C41-201201318


Pierre Allard
Director, Business Development
5521 De l'Aéroport Road
Valcourt, QC 
J0E 2L0

Subject:  Tariff notice 71 – Carrier Access Tariff for Local Network Interconnection

Mr. Allard:

On 2 February 2012, the Commission received the above-mentioned tariff notice from CoopTel. In its application, CoopTel indicated that the proposed tariff was consistent with the Commission's determinations in CoopTel – Implementation of local competition for Cogeco Cable Inc., Telecom Decision CRTC 2012-36, 24 January 2012. The company indicated that its application qualified as a Group B retail filing pursuant to Approval processes for tariff applications and intercarrier agreements, Telecom Information Bulletin 2010-455, 5 July 2010 (Information Bulletin 2010-455).

Commission staff reviewed CoopTel's application, and considers that a number of changes are necessary, as described below.

In its tariff proposal, CoopTel indicated that according to the current tariff, the competitive local exchange carrier (CLEC) would be considered to be a customer of CoopTel. Commission staff notes that in Decision 97-8,1 which established the regulatory framework for the implementation of local competition, the Commission had adopted the principle that CLECs were not simply customers of incumbent local exchange carriers (ILECs), but rather carriers of equal stature to the ILECs in the local exchange market.  Commission staff therefore considers that the statement should be deleted from CoopTel's tariff proposal.

CoopTel also indicated that the CLEC would be responsible for providing, at its own expense, half the distance between the point of interconnection (POI) between it and CoopTel. Commission staff notes that CoopTel's proposal does not reflect the Commission's conclusion in Decision 97-8, in which it prescribes the equal sharing of the costs of interconnection. Staff also notes that in Decision 97-8 the Commission permitted CLECs to establish their own calling areas for the purpose of establishing retail tariffs, contrary to what is stipulated in CoopTel's tariff proposal. Therefore, the Commission considers that those statements should be deleted from CoopTel's tariff proposal.

As for billing for linking charges, Commission staff notes that Telecom Order 98-4862 stipulates that when a CLEC uses the network of a third party for the provision of signalling transmission and switching services, the signalling point of interconnection (SPOI) provided by the third party should be considered as being the CLEC's designated SPOI. The Commission considers that if CoopTel uses the network of a third party to establish its signalling point of interconnection, the CLEC is not required to pay interconnection charges associated with CoopTel’s traffic. Commission staff therefore considers that CoopTel amend its tariff accordingly.

Further, Commission staff notes that CoopTel included provisions for the treatment of imbalance traffic compensation which, in accordance with Telecom Decision
2010-787,3 apply only to the operating territories of Bell Aliant Regional Communications, Limited Partnership, and Bell Canada. Commission staff therefore considers that it is appropriate to remove those provisions from CoopTel’s tariff proposal.

Accordingly, staff requires CoopTel to file an amended application that includes the changes set out in the Appendix no later than 23 February 2012.

Moreover, Commission staff considers that this application does not satisfy the definition of Group B retail tariff filings set out in Information Bulletin 2010-455, since it does not address services provided to retail customers, but rather services that would be provided only to competitors.  For purposes of efficiency, therefore, the Commission will process this application as a Competitor tariff filing rather than close the file and require the company to re-file it as a new application.

The application will therefore follow the procedure described in Information Bulletin
2010-455 regarding competitor tariffs:

Accordingly, the company is not to implement the proposed amendments until the Commission has rendered its determination regarding this application in the form of an order.

Yours sincerely,

[Original signed by] 

Suzanne Bédard
Senior Manager, Tariffs

cc. Sylvie Labbé, CRTC, 819-953-4945,

[1]Local competition, Telecom Decision CRTC 97-8, 1 May 1997.


[3]Bell Aliant Regional Communications, Limited Partnership and Bell Canada - Proposed revision to the treatment of imbalance traffic compensation, Telecom Decision CRTC 2010-787, 25 October 2010, amended by Telecom Decision CRTC 2010-787-1, 16 August 2011.


Appendix – Requested changes to CoopTel's tariff proposal

CoopTel is to make the following changes to its tariff proposal:

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